MTAX 6431 - Inbound International Taxation

An inbound transaction deals with a foreign person (e.g., a foreign individual, partnership, or corporation) doing business in the U.S. This course begins by discussing that a foreign person is taxed on two types of U.S. income: (1) FDAP (generally, investment income) and (2) effectively connected income (business income). FDAP includes a foreign person investing in marketable securities, as well as key planning issues when a foreign person invests in U.S. real estate. The effectively connected income discussion includes the branch profits tax. Planning opportunities such as avoiding U.S. income tax when a foreign person exports goods into the U.S.; choice of U.S. business entity; and structuring U.S. business entities between different foreign tax systems (world-wide taxation by the foreign country or territorial taxation by the foreign country) are also presented. Restriction: Restricted to graduate business majors and NDGR majors with a sub-plan of NBA or CPA within the Business School. Max hours: 3 Credits. Semester Hours: 3 to 3